On Appeal

In a decision this term, the Rhode Island Supreme Court reminded practitioners that it may affirm decisions granting summary judgment on grounds other than those relied upon by the motion justice.  See Beauregard v. Gouin, No. 2010-434-Appeal at 10 n.7 (citing Lavoie v. North East Knitting, Inc., 918 A.2d 225, 228 (R.I. 2007)).  In that case, the Court concluded that the trial court properly granted summary judgment in favor of the defendant on plaintiff’s claim for slander of title because one of the necessary elements for such a claim was absent.  Id. at 8-9.  On appeal, the plaintiff argued that the trial court also erred with respect to its conclusions on a different element of the slander of title claim.  Id. at 10 n.7.  Having already concluded that one of the necessary elements was absent, the Court affirmed the trial court’s decision on that basis alone and declined to address the plaintiff’s arguments with respect to the other elements of the slander of title claim.  Id.